Breach details

An unencrypted, unsecured laptop containing the details of 970 individuals who had attended hospitality events organised by Panasonic UK was stolen from an unlocked hotel room. These events were being run by a third party company on behalf of Panasonic, and Panasonic’s comprehensive data protection policies that would have prevented this breach were therefore not automatically applied. However, it appears that these policies were not communicated to the company and the data protection provisions listed in the contract were extremely limited. Moreover, passport information was collected from all guests and then retained regardless of whether this information was necessary.

Regulatory action

Regulator

ICO

Action

Undertaking to comply with the seventh data protection principle.

When

Unknown.

Details

Panasonic UK is to ensure that all third party company data controllers are governed by adequate contracts and checks to ensure that they are complying with data protection policies. Panasonic are also to ensure that personal data is only collected for a specified, valid purpose and is not retained for longer than is necessary. Other security measures should be implemented as appropriate.

Breach details

These police forces were part of the East Midlands Collaboration Unit (EMCU), whose offices were burgled in August 2010. Eight laptops belonging to seconded offices were stolen; they had not been stored in available lockable containers and two were unencrypted. Derbyshire and Leicestershire Police had not undertaken their own risk assessments and relied on the security measures of Nottingham Police. However, this did not specify that laptops should be encrypted, made no provision for locking them in containers, and did not monitor the offices during this period.

Regulatory action

Regulator

ICO

Action

Enforcement Notice issued to limit the sharing of personal data.

When

18 June 2013

Details

These police forces shall only share personal data as part of a collaborative project if a Senior Information Risk Owner has been appointed to oversee the work and risk assess the premises; laptop and other portable electronic security devices are encrypted; and all officers involved in the project are given appropriate training. These measures should been implemented within 35 days.

Breach details

What

Personal data, including some bank account details, on two stolen unencrypted laptops.

How much

At least 20,143 records.

When

28 May 2012

Why

Two unencrypted laptops were stolen from an office in the process of being refurbished. Employee 1 had locked up her laptop and left the key in Employee 2’s drawer. Employee 2 put his laptop in his storage drawer but failed to lock it. Both laptops were stolen. Employee 2’s laptop contained the council’s creditor payment history file, including 20,143 personal names ad addresses and 6,069 bank account details. About 74 other unencrypted laptops are unaccounted for, of which six are known to have been stolen.

Regulatory action

Regulator

ICO

Action

Monetary penalty of £ 150,000

When

04 June 2013

Why the regulator acted

Breach of act

Breach of the seventh principle: the Council failed to take appropriate technical measures to prevent the loss of personal data from laptops, such as implementing port control and encrypting laptops.

Known or should have known

In spite of enforcement action taken against the Council in 2010 concerning failings related to unencrypted laptops, unencrypted laptops were still in use in 2012, in breach of the Council’s own policy. It should have been obvious the risks were increased by the physical insecurity of the offices undergoing refurbishment. The Commissioner also highlighted his own well-known guidance on the encryption of portable media, dating back to 2007.

Likely to cause damage or distress

As usual, the Commissioner’s argument is that data subjects are likely to have suffered from substantial distress knowing that their personal data may be disclosed to third parties who have no right to see that information. Additionally if the data is disclosed to ‘untrustworthy third parties’ there is the potential that the data subjects may be exposed to identity theft.

Breach details

An earlier enforcement notice was issued in 2010. Since then, previous thefts had occurred from the Council’s offices and physical security had not been improved. In addition, unencrypted laptops were still being issued and over 70 unencrypted laptops were unaccounted for.

BW Comments

A Monetary Penalty Notice was issued to Glasgow in respect of this breach but the quality of IT asset management at the Council was obviously so poor that the ICO felt it needed to issue an enforcement notice as well.

Regulatory action

Regulator

ICO

Action

Enforcement Notice

When

04 June 2013

Details

Enforcement Notice issued to ensure that asset management is improved. A full audit of existing IT assets relating to personal information must be undertaken by 30 June 2013, along with asset management training for managers and reissuing information security guidelines to staff. A new asset register must be completed by 31 July 2013 and updated on a yearly basis.

WhyThe Edinburgh Evening News reported that an unencrypted laptop containing sensitive personal data relating to vulnerable children was stolen from the home of a consultant who conducts reviews of foster and adoptive parents in Edinburgh.

The police believe that the data on the laptop was not targeted, and the Council claims to have contacted “as many as possible” of those whose details were contained on the laptop.

Working with BT the City of Edinburgh Council had taken measures to encrypt some 8000 computers belonging to the council, following an IT security review in 2010. It would appear that the issue here was a failure to ensure that third parties also handling this data followed the same security measures.

What

Loss of personal and sensitive personal data.

How much

40 records.

Why

Theft of an unencrypted laptop from a locked ground floor office in the Newcastle area.

Regulator

ICO

Regulatory action

Undertaking issued to ensure that portable and mobile devices including laptops are encrypted to a sufficient standard. Physical security standards must be adequate to prevent unauthorised access to personal data.

Reason for action

The stolen laptop was password protected, but had not been encrypted, However the data controller proposed to improve physical software and implement encryption as a result of the incident.

Regulator

Regulatory action

Reason for action

Whilst neither laptop has been recovered to date they did not contain any sensitive personal data. Since the incident occurred the data controller has ensured the encryption of mobile devices that contain personal data and provided all employees with data protection training.

What

How much

Why

An unencrypted laptop containing a database with child swimming lessons was stolen from a ground level office at a swimming pool.

Regulator

ICO

Regulatory action

Undertaking issued to ensure that all portable media devices containing personal data are sufficiently encrypted. These devices must be secured when not in use.

Reason for action

Despite several security devices and the rapid arrival of police officers the thief was able to remove the laptop and escape, as the laptop was left unsecured on a desk in a position where it could be seen from outside the office.

What

How much

Why

Theft of an unencrypted laptop during a burglary and on a separate occasion details of an employee’s income and salary deductions was accidently emailed to 2,821 employees.

Regulator

ICO

Regulatory action

Undertaking issued to ensure that that all portable media devices are suitably encrypted and appropriate administrative measures are put into place to control employee use of email groups.

Reason for action

The laptop was stolen from the home of a sessional worker, a casual employee under contract for a specific assignment. The data sent to the worker was supposed to have been anonymised, but had not been.